Saving Clause – Citizenship Taxation

Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax”

cross-posted from citizenshipsolutions blog by John Richardson Beginning with the conclusion (for those who don’t want to read the post) … For the reasons given in this post, I believe that there are grounds to argue that the imposition of the Sec. 965 “transition tax” on Canadian resident/citizens DOES violate the Canada U.S. taxContinue reading “Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax””

Hands Down this is the Worst Academic Piece About FATCA ever Written

CONSIDERING "CITIZENSHIP TAXATION":IN DEFENSE OF #FATCA– Hands Down Worst Academic Piece About FATCA ever Written https://t.co/qYvsrzpEyL — Patricia Moon (@nobledreamer16) May 27, 2017 Profesor Paul Caron, on his TaxProfBlog posted the following article: CONSIDERING “CITIZENSHIP TAXATION”: IN DEFENSE OF FATCA 20 Fla. Tax Rev. 335 (2017): by Young Ran (Christine) Kim IfContinue reading “Hands Down this is the Worst Academic Piece About FATCA ever Written”

The U.S. Saving Clause Facilitates the Expatriation Tax in 877A

What is evident is that our governments do not understand the effects of citizenship-based taxation. They did not believe us when we told them it was not just an issue of possibly not owing annual income tax. They did not believe us when we told them our tax-deferred accounts would be taxed. They didContinue reading “The U.S. Saving Clause Facilitates the Expatriation Tax in 877A”